Nevada Underground Injection Control Permit (14-NV-c)
Underground Injection Control Permit Process
14-NV-c.1 – Pre-application Meeting (Optional)
NDEP recommends that an applicant arrange a pre-application meeting with the following entities:
- Nevada Division of Environmental Protection (NDEP), Bureau of Water Pollution Control;
- Nevada Division of Minerals (NDOM);
- Nevada Division of Water Resources (DWR);
- Bureau of Land Management (BLM)
An applicant should use this meeting to present the project and obtain the necessary information to submit a complete and comprehensive application. At a minimum, the applicant should meet with the UIC Program staff to discuss details of the application.
14-NV-c.2 – Underground Injection Control Permit (UIC Forms U200, U202)
The Underground Injection Control Program is administered by the Nevada Division of Environmental Protection (NDEP). The UIC program is governed by NRS 445A.300-445A.730 and NAC 445A.810-445A.925. NDEP has provided more specific information on the UIC Program at their webpage.
Nevada has divided injection wells into five classes according to federal regulations in the Safe Drinking Water Act of 1977. Class I and Class IV wells are prohibited in Nevada UIC regulations. A permit is required in Nevada for all injection activities regardless of well class. A UIC Permit can be issued for individual injection wells; however, one Area Permit may be issued for as many injection wells are within a project area. All UIC Permits will state the number of permitted injection wells that can be served by the permit.
Below are the appropriate permit application forms:
- UIC Permit Application: Form U200
- UIC Permit Application Attachments, Class 2, 3, or 5 Geothermal Wells: Form U202
These forms must be signed by the owners or operator of the injection wells and include the listed requirements in NAC 445A.867. Required UIC permit fees are based on the type of geothermal project, the size or flowrate of the project, and the number of injection wells which will be permitted at the project. An updated fee schedule is found at NAC 445A.872.
NAC 445A.860 allows the applicant to maintain some information confidential throughout the application process. The claim for confidentiality must be asserted at the time of submission by marking “confidential business information” on each page containing the information. NDEP allows the following information to remain confidential though the application process:
- All well/resource logs (excluding non-sensitive integrity test logs);
- Subsurface geologic;
- Completion reports containing sensitive business information;
Information such as the total depth of well, plugging report, APDs, and other non-sensitive business information will not be held confidential by NDEP.
14-NV-c.3 to 14-NV-c.4 – Review Application Materials for Completeness
A completeness review of the UIC application will be concluded within a minimum of 30 days by NDEP. Any applications which are not complete will be returned to the applicant as denied.
14-NV-c.5 – Conduct Technical Review
A technical review of the project will be concluded within 60 days by NDEP. All information will be evaluated to determine compliance with applicable statutes and regulations. Some additional information may be requested by NDEP from the applicant at this point as required.
14-NV-c.6 – Publish Notice of Intent to Issue/Deny Permit
14-NV-c.7 - Public Comment Period
The public review and comment period for all injection permits is 30 days. A public hearing may be requested. Within 30 days after the end of the public notice and comment period, a UIC permit will be issued or denied. Note that final injection approval before operation comes after issuance of a construction permit for each injection well.
14-NV-c.8 to 14-NV-c.9 - Has a Public Hearing Been Requested?
A public hearing may be requested for any UIC permit by written notice to the agency.
14-NV-c.10 – Will Drinking Water Be Endangered?
Pursuant to UIC Regulations in NAC 445A.865 – 445A.925, any underground injection program may not “endanger any source of drinking water” NAC 445A.867. NDEP may not permit any project which is found to violate these provisions.
14-NV-c.11 – Has Developer Posted Adequate Surety Bond with NDOM?
Commercial geothermal injection well permittees are required by the Nevada Division of Minerals (NDOM) regulations to post a surety bond in favor of the State in the amount of at least $10,000 per well or $50,000 for state-wide guarantee that abandoned wells will be properly plugged. NDEP may use the same bond filed with NDOM to satisfy the bond requirement under the UIC Program. However, NDEP may require additional bonding if necessary for a particular well. The BWPC UIC Program Description has more information in the “Financial Assurance” section.
14-NV-c.12 – Underground Injection Permit
Pursuant to the Nevada Revised Statutes, a UIC Permits are issued for 5 years periods. After the 5-year period is expired, the permit needs to be renewed. Renewal Applications are due to NDEP 180 days prior to the permit’s expiration. Nevada law allows the permitee to continue to operate under an expired permit if the renewal application has been received by NDEP but has not yet been reviewed and renewed.
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